### IDEM INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

We Protect Hoosiers and Our Environment. Mitchell E. Daniels Jr. 100 North Senate Avenue Governor Indianapolis, Indiana 46204 (317) 232-8603 Thomas W. Easterly Toll Free (800) 451-6027 Commissioner www.idem.IN.gov

May 31, 2011

Ms. Susan Hedman Regional Administrator U.S. Environmental Protection Agency Region 5 77 West Jackson Boulevard Chicago, IL 60604-3950

Dear Ms. Hedman:

Re: Request for Redesignation Petition and Maintenance Plan Under the Annual National Ambient Air Quality Standard for Fine Particles for the Central Indiana Nonattainment Area

The Indiana Department of Environmental Management (IDEM) submits a Redesignation Petition and Maintenance Plan for the Central Indiana Nonattainment Area, which was designated as non attainment of the annual standard for fine particles on April 5, 2005. IDEM conducted a public hearing concerning the Redesignation Petition and Maintenance Plan on May 17, 2011, and the public comment period concluded on May 19, 2011.

This submittal documents the public review process, including a detailed summary of, and response to, substantive comments.

The attached document consists of the following:



### Redesignation Petition and Maintenance Plan • A formal request that the Central Indiana Area be redesignated to attainment and reclassified as maintenance. It contains and meets the requirements set forth in Section 107 of the Clean Air Act and in United States Environmental Protection Agency (U.S. EPA) Redesignation Guidance.

• A maintenance year of 2025 is established and 2015 and 2020 are analyzed as interim years.

• The appendices of the document contain historical air quality trend data, projected emission inventory data, and thorough documentation of the mobile emissions analysis.

Recycled Paper (i) An Equal Opportunity Employer Please Recycle 

### 0Ms. Hedman Page 2

Motor Vehicle Emissions Budgets

• Contained in the Redesignation Petition is a new Motor Vehicle Emissions Budget for 2015 and 2025. The Indianapolis Department of Metropolitan Development's travel demand forecasting model and the U.S. EPA's software program referred to

as MOBILE6.2 were used to determine emissions for the annual fine particle nonattainment area.

• A conservative margin of safety was applied to the 2015 and 2025 projected emissions.

• The travel demand model was updated with the best available assumptions.

• Vehicle registration data gathered from the Indiana Bureau of Motor Vehicles were used to replace the MOBILE6.2 default vehicle age distribution.

Combined with the October 20, 2009 submittal, IDEM requests that U.S. EPA proceed with review and approval of this submittal. If you have any questions or need additional information, please contact Scott Deloney, Chief, Air Programs Branch, at (317) 233-5694.

Sincerely,

# I~**(J)~r** Keith Baugues Assistant Commissioner Office of Air Quality

KB/sad/skr Enclosure: Request for Redesignation Petition and Maintenance Plan Under the Annual National Ambient Air Quality Standard for Fine Particles for the Central Indiana Nonattainment Area

Cc: John Summerhays, U.S. EPA Region 5 (wi enclosures) Matt Rau, U.S. EPA Region 5 (wi enclosures) John Mooney, U.S. EPA Region 5 (no enclosures) Cheryl Newton, U.S. EPA Region 5 (no enclosures) Pat Morris, U.S. EPA Region 5 (no enclosures) Scott Deloney, IDEM (no enclosures) Christine Pedersen, IDEM (no enclosures) Sarah Raymond, IDEM (wi enclosures)

# REQUEST FOR REDESIGNATION AND MAINTENANCE PLAN UNDER THE ANNUAL NATIONAL AMBIENT AIR QUALITY STANDARD FOR FINE PARTICLES

Central Indiana Area

Prepared By: The Indiana Department of Environmental Management

May 2011ii This page intentionally left blankiii TABLE OF CONTENTS

1.0 INTRODUCTION

.................................................................................................................... 1 1.1 Background ................................................................................................................ ................1 1.2 Geographical Description .................................................................................................. ........3 1.3 Status of Air Quality ..................................................................................................... .............3

2.0 REQUIREMENTS FOR REDESIGNATION

...................................................................... 3 2.1 General ................................................................................................................... ....................3 2.2 Fine Particles Monitoring ................................................................................................. .........3 2.3 Emission Inventory ........................................................................................................ ............4 2.4 Modeling Demonstration .................................................................................................... .......4 2.5 Controls and Regulations .................................................................................................. .........4 2.6 Corrective Actions for Potential Future Viol ations of the Fine Particle Standard ....................5

3.0 FINE PARTICLES MONITORING

..................................................................................... 5 3.1 Fine Particles Monitoring Network ......................................................................................... ..5 3.2 Ambient Fine Particles Monitoring Data ...................................................................................7 3.3 Quality Assurance ......................................................................................................... ...........10 3.4 Continued Monitoring ...................................................................................................... ........10

4.0 EMISSION INVENTORY

.................................................................................................... 10 4.1 Emission Trends ........................................................................................................... ............10 4.2 Base Year Inventory ....................................................................................................... .........18 4.3 Emission Projections ...................................................................................................... ..........18 4.4 Demonstration of Maintenance .............................................................................................. ..22 4.5 Permanent and Enforceable Emission Reductions ..................................................................23 4.6 Provisions for Future Updates ............................................................................................. ....23

5.0 TRANSPORTATION CONFORMITY BUDGETS ..........................................................23 5.1 Onroad Emission Estimates ................................................................................................. ....23 5.2 Overview .................................................................................................................. ................25 5.3 Analysis Years ............................................................................................................ .............25 5.4 Emission Estimates ........................................................................................................ ..........25 5.5 Motor Vehicle Emission Budget ............................................................................................. .26 5.6 Commitment to Amend Motor Vehicle Emissi on Budgets Using Motor Vehicle Emission Simulator (MOVES) ...............................................................................................26iv 6.0 CONTROL MEASURES AND REGULATIONS ..............................................................27 6.1 Reasonably Available Control Technology (RACT) ...............................................................27 6.2 Implementation of Past State Implementation Plan (SIP) Revisions.......................................27 6.3 Nitrogen Oxides (NO x ) Rule ....................................................................................................27 6.4 Measures Beyond Clean Ai r Act SIP Requirements ...............................................................28 6.5 Controls to Remain in Effect .............................................................................................. .....32 6.6 New Source Review Provisions .............................................................................................. .32

7.0 MODELING AND METEOROLOGY ................................................................................33 7.1 Summary of Modeling Results to Support Rulemakings ........................................................33 7.2 Lake Michigan Air Directors Consortiu m (LADCO) Round 5 Speciated Modeled Attainment Test Results ....................................................................................................... ....36 7.3 LADCO Round 5 Fine Particle Source Apportionment Results .............................................37 7.4 Summary of Existing Modeling Results ..................................................................................41 7.5 Meteorological Analysis for Central Indiana ...........................................................................41 7.6 Surface Air Conditions Present During High Fine Particle Concentration Days ....................41 7.7 Upper Air Conditions Present During High Fine Particle Concentration Days ......................41 7.8 Analysis of Atmospheric Conditions During High Fine Particle Concentration Days ...........42 7.9 Summary of Air Quality Index ( AQI) Days in Central Indiana ..............................................42 7.10 Summary of Meteorological An alysis for Central Indiana ....................................................44

8.0 CORRECTIVE ACTIONS ...................................................................................................44 8.1 Commitment to Revise Plan ................................................................................................. ...44 8.2 Commitment for Con tingency Measures .................................................................................44 8.3 Contingency Measures ...................................................................................................... .......45

9.0 PUBLIC PARTICIPATION ................................................................................................46

10.0 CONCLUSIONS ..................................................................................................................46

FIGURES

Figure 3.1 Central Indiana Nonattainment Area ..............................................................................6 Figure 5.1 Central Indiana Metropolitan Planning Organization Jurisdictions .............................24v CHARTS

Chart 7.1 Regional/Emission Sector Part iculate Source Apportionment Technology (PSAT) Results by Sector for Marion County at E. Michigan Street Fine Particles (PM 2.5 ) Monitor ....................................................................................................................... ...38 Chart 7.2 Regional/Pollutant Sector PSAT Results by Cont ribution for Marion County at E. Michigan Street PM 2.5 Monitor .................................................................................38 Chart 7.3 Species Modeled Contributions to W. 18 th Street PM 2.5 Monitor in Marion County ....................................................................................................................... ....39 Chart 7.4 Species Modeled Contributions to Washington Park PM 2.5 Monitor in Marion County ...................................................................................................................... ....39 Chart 7.5 Species Modeled Contributions to E. 75 th Street PM 2.5 Monitor in Marion County .....40 Chart 7.6 Species Modeled Contributions to Mann Road PM 2.5 Monitor in Marion County .......40 Chart 7.7 Species Modeled Contributions to E. Michigan Street PM 2.5 Monitor in Marion County ....................................................................................................................... ....40 Chart 7.8 Distribution of PM 2.5 Concentration Days in Cent ral Indiana on the AQI Levels of Health Concern .........................................................................................................43

TABLES

Table 1.1 National Ambient Air Quality Standards for Fine Particles ............................................2 Table 3.1 Monitoring Data for the Central Indiana Area .................................................................7 Table 4.1 Comparison of 2008 Estimated a nd 2025 Projected Emission Estimates .....................22 Table 5.1 Emission Estimates for Onroad Mobile Sources ...........................................................25 Table 5.2 Motor Vehicle Emission Budgets ..................................................................................26 Table 6.1 Trends in Electric Generating Unit (EGU) NO x Emissions Statewide in Indiana .........28 Table 7.1 Clean Air Transport Rule M odeling Results from U.S. EPA - 2010 .............................33 Table 7.2 Clean Air Transport Rule M odeling Results from U.S. EPA – 2010 ............................35 Table 7.3 LADCO Round 6 Modeling Results for Annual PM 2.5 – Without the Clean Air Interstate Rule Emission Reductions .............................................................................35 Table 7.4 LADCO Round 5 SMAT Modeli ng Results for Central Indiana ..................................37 Table 7.5 Ranking and Percentage of Highest Number of Days at AQI Levels of Health Concern ...................................................................................................................... ...43vi GRAPHS

Graph 3.1 Design Values for the Central Indiana Area for Fi ne Particles, 2006 through 2010 .................................................................................................................. ..8 Graph 3.2 Central Indiana Annual Fine Particles Trends, 2006 through 2010 ................................9 Graph 4.1 Central Indiana Area NO x Point Source Emission Trends, 2002, 2006, and 2008 .......11 Graph 4.2 Central Indiana Area Sulfur Dioxide (SO 2 ) Point Source Emission Trends, 2002, 2006, and 2008 ....................................................................................................11 Graph 4.3 Central Indiana Area Direct PM 2.5 Point Source Emission Trends, 2002, 2006, and 2008 ..................................................................................................................... ...12 Graph 4.4 NO x Emission Trends, All Sources in the Central Indiana Area, 2002, 2006, and 2008 ..................................................................................................................... ...13 Graph 4.5 SO 2 Emission Trends, All Sources in the Central Indiana Area, 2002, 2006, and 2008 ..................................................................................................................... ...13 Graph 4.6 Direct PM 2.5 Emission Trends, All Sources in the Central Indiana Area, 2002, 2006, and 2008 ..............................................................................................................1 4 Graph 4.7 NO x Emissions from EGUs, Central Indiana Area, 1999 to 2009 ................................15 Graph 4.8 SO 2 Emissions from EGUs, Central Indiana Area, 1999 to 2009 ................................16 Graph 4.9 Indiana Statewide NO x Emissions from EGUs, 1999 to 2009 ......................................17 Graph 4.10 Indiana Statewide SO 2 Emissions from EGUs, 1999 to 2009 ....................................17 Graph 4.11 Comparison of 2005 and 2008 Estimated and 2015, 2020, and 2025 Projected NO x Emissions for the Ce ntral Indiana Area ................................................................20 Graph 4.12 Comparison of 2005 and 2008 Estimated and 2015, 2020, and 2025 Projected SO 2 Emissions for the Central Indiana Area .................................................................20 Graph 4.13 Comparison of 2005 and 2008 Estimated a nd 2015, 2020, and 2025 Projected Direct PM 2.5 Emissions for the Central Indiana Area ...................................................21 Graph 4.14 Comparison of 2005 and 2008 Estimated and 201 5, 2020, and 2025 Projected NO x , SO 2 , and Direct PM 2.5 Emissions Trends for the Central Indiana Area ..............21 Graph 7.1 PM 2.5 Design Value Trends for the Central Indiana Area: 2000 - 2010 .......................34 Graph 7.2 LADCO Modeling Resu lts for Central Indiana PM 2.5 Monitors for 2012 and 2018 ......................................................................................................................... ......36vii APPENDICES

A Air Quality System (AQS) and Indiana De partment of Environmental Management (IDEM) Monitor Data Values for the Central Indiana Area (2000-2010) B NO x , SO 2 , and Direct PM 2.5 Point Source Emissions (2002, 2006, and 2008) for Central Indiana Area C NO x , SO 2 , and Direct PM 2.5 Emission Trends, All Sources, (2002, 2006, and 2008) for Central Indiana Area. D NO x and SO 2 Emissions from EGUs, Central Indiana Area E 2006 and 2008 Base Years Emission Inve ntories and 2015, 2020, and 2025 Projected Emission Inventories for NO x , SO 2 , and Direct PM 2.5 for Central Indiana Area F Mobile Source Input and Output Calcul ation Files for Central Indiana Area G IDEM – Area Source Inventory Standard Operating Procedure H Modeling Summary I LADCO Emission Estimates Technical Support Document J LADCO Round 5 Modeling Technical S upport Document (Round 5 Photochemical Modeling Based on “Base M” Emissions I nventory, revised version of “Base K”) K Public Participation Process Documentsviii This page intentionally left blank1 REQUEST FOR REDESIGNATION AND MAINTENANCE PLAN UNDER THE ANNUAL NATI ONAL AMBIENT AIR QUALITY STANDARD FOR FINE PARTICLES

CENTRAL INDIANA AREA

1.0 INTRODUCTION

This document supports Indiana’s request th at Hamilton, Hendricks, Johnson, Marion, and Morgan counties (herein referred to as the “C entral Indiana Area”), be redesignated from nonattainment to attainment of the 1997 annual standard for fine part icles. All monitors for fine particles in the Central Indiana Area have recorded three years of quality assured ambient air quality monitoring data for the years 2008 thr ough 2010, demonstrating attainment with the annual standard for fine particles, therefor e, the Central Indiana Area is eligible for redesignation.

Section 107 of the Clean Air Act (CAA) establishe s specific requirements to be met in order for an area to be considered fo r redesignation, including:

(a) A determination that the area has attained the annual standard for fine particles. (b) A State Implementation Plan (SIP) for the area under Section 110(k) is fully approved. (c) A determination that the improvement in air quality is due to permanent and enforceable reductions in emissions resul ting from implementation of the SIP and other federal requirements. (d) A maintenance plan under Sect ion 175A is fully approved. (e) A determination that all Section 110 and Part D requirements have been met.

A maintenance plan provides for the continued atta inment of the air quality standard by an area for a period of ten years after the United Stat es Environmental Protection Agency (U.S. EPA) has formally redesignated the area to attainment. The plan also pr ovides assurances that even if there is a subsequent exceedance of the air quality standard, then measures in the maintenance plan will prevent any future occurrences through contingency measures that would be triggered.

This document addresses each of these requireme nts, and provides additional information to support continued compliance with the a nnual standard for fine particles.

1.1 Background

The CAA requires states with areas designate d nonattainment of th e applicable National Ambient Air Quality Standard (NAAQS) for fine particles to develop SI Ps to expeditiously attain and maintain the standar d. In 1997, U.S. EPA set daily and annual air quality standards for fine particles (PM 2.5 ), as shown in Table 1.1. The terms “fine particles” and PM 2.5 ” are used synonymously throughout this document. The PM 2.5 standards were legally challenged and upheld by the U.S. Supreme Court in February of 2001. In 1999, the Indiana Department of2 Environmental Management (IDEM) began monitori ng for fine particle concentrations. The U.S. EPA designated areas in Indiana under the annual fine particles standard on December 17, 2004, as attainment, nonattainment or unclassifiabl e, with an effective date of April 5, 2005.

Table 1.1 National Ambient Air Quality Standards for Fine Particles

Annual 24-Hour

1997 PM 2.5 Standards 15 μg/m 3 Annual arithmetic mean, averaged over three years 65 μg/m 3 24-hour average, 98 th percentile, averaged over three years

2006 PM 2.5 Standards 15 μg/m 3 Annual arithmetic mean, averaged over three years 35 μg/m 3 24-hour average, 98 th percentile, averaged over three years
Note: The Central Indiana Area meets the 1997 and 2006 24-hour NAAQS for fine particles. Since this area is solely designated nonattainment under the 1997 annual standard for fine particles, this document only addresses the annual standard.

On December 17, 2004, based on 2001 through 2003 monitoring data, U.S. EPA designated the Central Indiana Area as nonattainment of the annual standard for fine particles. The Central Indiana Area was subject to Section 172 of the CAA, including the development of a plan to reduce nitrogen oxides (NO x ), sulfur dioxide (SO 2 ), and direct PM 2.5 particle emissions and a demonstration that the area will meet the annual standard for fi ne particles by April 5, 2010. In order to satisfy these requirements, Indiana s ubmitted a redesignation petition and maintenance plan to U.S. EPA on October 20, 2009, demonstra ting that the Central In diana Area had met the NAAQS for fine particles by April 5, 2010, with an ample margin of safety. The Central Indiana Area monitors have continued to meet the annu al NAAQS for fine part icles since the end of 2007.

There were no fine particle monitors in the Ce ntral Indiana Area that violated the 1997 24-hour standard for fine particles and none that curr ently violate the 2006 24-hour standard for fine particles. As a result, the Central Indiana Ar ea was designated nonattainment for fine particles solely under the 1997 annual sta ndard. Therefore, this document pertains only to the 1997 annual standard for fine particles.

The Central Indiana nonattainment area for fine particles, as define d in Section 1.2, has not previously been subject to nonatta inment area rulemakings for fine particles. However, Marion County was subject to nonattain ment area rulemakings under the 1-hour ozone standard. The 1- hour ozone standard was revoked on June 15, 2005. Boone, Hamilton, Hancock, Hendricks, Johnson, Madison, Marion, Morgan, and Shelby c ounties in Central Indi ana had also been subject to nonattainment area ru lemakings under the 8-hour ozone standard and all counties in Central Indiana were redesignated to attainment and classified as maintenance under the 8-hour ozone standard on October 19, 2007.3 1.2 Geographical Description

The Central Indiana nonattainment area for a nnual fine particles consists of Hamilton, Hendricks, Johnson, Marion, and Morgan counties. The Central Indiana Area includes cities such as Beech Grove, Carmel, Franklin, Greenw ood, Indianapolis, Lawrence, Martinsville, and Noblesville and such towns as Avon, Brownsbur g, Fishers, Mooresvill e, Plainfield, and Speedway. This area is depicted in Figure 3.1.

IDEM is the agency responsible for assuring the nona ttainment area for fine particles complies with the CAA requirements and is responsible fo r the entire Central I ndiana Area. IDEM has worked cooperatively with U.S. EPA Region V to address attainment planning issues.

1.3 Status of Air Quality

Monitoring data for fine particles for the th ree years, 2008 through 2010, demonstrates that air quality has met the annual NAAQS for fine particle s in the Central Indian a Area. This fact, accompanied by the permanent and enforceable reductions in emission levels discussed in Section 4.0, justifies a redesignati on to attainment for the Centra l Indian area based on Section 107(d)(3)(E) of the CAA.

2.0 REQUIREMENTS FOR REDESIGNATION

2.1 General

Section 110 and Part D of the CAA list a num ber of requirements that must be met by nonattainment areas prior to consideration for rede signation to attainment. In addition, U.S. EPA has published detailed guidance in a document en titled “Procedures for Processing Requests to Redesignate Areas to Attainment”, issued Sept ember 4, 1992, to Regional Air Directors. This document is hereafter referred to as “Redesigna tion Guidance”. This Request for Redesignation and Maintenance Plan is based on the Redesi gnation Guidance, supplemented with additional guidance received from staff of the Attainment Planning and Maintenanc e Section of U.S. EPA Region V. The specific requirements for redesignation are listed below.

2.2 Fine Particles Monitoring

1) A demonstration that the annual standard for fine particles, as published in 40 Code of Federal Regulations (CFR) 50.13, has been attained. Fine particle monitoring data must show that violati ons of the annual ambient standard are no longer occurring.

2) Ambient monitoring data quality a ssured in accordance with 40 CFR 58.15, recorded in the U.S. EPA Air Quality Sy stem (AQS) database, and available for public view.4 3) A showing that the three-year average of annual values, based on data from all monitoring sites in the area or its aff ected downwind environs, do not exceed 15.0 micrograms per cubic meter (μg/m 3 ). This showing must rely on three complete, consecutive calendar years of quality assured data.

4) A commitment that, once redesignated, the state will continue to operate an appropriate monitoring network to verify the area is in compliance (maintenance) with the standard.

2.3 Emission Inventory

1) A comprehensive emission inventory of the precursors of fine particles (direct PM 2.5 , NO x and SO 2 ) completed for the base ye ar (2008 in this case).

2) A projection of the emission inventory to a year at least ten years following redesignation.

3) A demonstration that the pr ojected level of emissions is sufficient to maintain the annual standard for fine particles.

4) A demonstration that improvement in air quality between th e year violations occurred and the year attainment wa s achieved is based on permanent and enforceable emission reductions a nd not on temporary adverse economic conditions or unusually favorable meteorology.

5) Provisions for future updates of the i nventory to enable tr acking of the emission levels, including emission inventory statements from emission sources.

2.4 Modeling Demonstration

While no modeling is required for redesignating nonattainment areas, IDEM has evaluated the results of federal control-case modeling to demonstrate that compliance with the standard will be maintained.

2.5 Controls and Regulations

1) A U.S. EPA approved SIP control stra tegy that includes R easonably Available Control Technology (RACT) requirements fo r existing stationary sources covered by Control Technology Guidelines (CTG ) and non-CTG RACT for all major

sources.

2) Evidence that control measures required in past SIP revisi ons have been fully implemented.

3) Acceptable provisions to pr ovide for new source review.5 4) Assurances that existing controls will remain in effect after redesignation, unless the state demonstrates through photochemical modeling that the standard can be maintained without one or more controls.

5) If appropriate, a commitment to adopt a requirement that all transportation plans conform with, and are cons istent with, the SIP.

2.6 Corrective Actions for Potential Future Violations of the Fi ne Particle Standard

1) A commitment to submit a revised plan eight years af ter redesignation.

2) A commitment to expeditiously enact and implement additional contingency control measures in response to excee ding specified predetermined levels (triggers) or in the event that future vi olations of the ambient standard occur.

3) A list of potential contingency measures that would be implemented in such an
event.

4) A list of NO x , SO 2 , and direct PM 2.5 sources potentially subject to future controls.

3.0 FINE PARTICLES MONITORING

3.1 Fine Particles Monitoring Network

There are currently three Federal Reference Method monitors measuring fine particle concentrations in this nonattainment area. The monitors are located in Marion County at Washington Park, West 18 th Street, and East Michigan Street . The monitors are operated by IDEM’s Office of Air Quality (OAQ). A listi ng of the monitor readings from 2008 through 2010, are shown in Table 3.1 and Appendix A a nd was retrieved from U.S. EPA’s AQS database. The locations of the monitoring sites for this nonattainment area are shown in Figure 3.1.

IDEM also operates two fine particle monitors in Marion County (West Street and School 21) that are considered source oriented monitors. Wh ile the source oriented monitors are not used to determine attainment with the annual standard fo r fine particles, the monitoring locations and data are included as supporting material. Two monitors (Mann Road and East 75 th Street, both in Marion County) in the Central Indiana Area were discontinued at the end of 2007.6 Figure 3.1 Central Indiana Nonattainment Area7 3.2 Ambient Fine Particles Monitoring Data

The following information summarizes U.S. EP A's "Guideline on Data Handling Conventions for the PM NAAQS," U.S. EPA-454/R-99-008, Ap ril 1999. Three complete years of fine particle monitoring data are required to demonstr ate attainment at a monitoring site. The annual ambient air quality standard for fine particles is met at an am bient air quality monitoring site when the three-year average of the annual average of fine particle concentr ations is less than or equal to 15.0 μg/m 3 . When this occurs, the site is said to be in attainment. While calculating design values, three significant di gits must be carried in the co mputations, with final values rounded to the nearest 0.1 μg/m 3 . Decimals 0.05 or greater are rounded up, and those less than 0.05 are rounded down, so that 15.049 μg/m 3 is the largest concentration that is less than or equal to 15.0 μg/m 3 . Values at or below 15.0 μg/m 3 meet the standard. Values equal to or greater than 15.1 μg/m 3 exceed the standard.

Data handling procedures are applied on an indi vidual basis at each monitor in the area. An individual site’s three-year av erage of the annual average fine particles concentr ation is also called the site’s design value . An area is in compliance w ith the annual NAAQS for fine particles only if all monitoring sites meet the NAAQS. The air quality design value for the area is the highest design value among all sites in the area. Table 3.1 outlines the annual fine particle values by site and the 2008 through 2010 design va lues for the three ac tive fine particle monitoring sites in the Centra l Indiana nonattainment area. The nearby Anderson monitor is included for supporting material. Appendix A contains the comp lete monitoring data summary from 2000 to 2010 for all of the Central Indiana m onitors which includes the three active fine particle monitoring sites, the Ande rson monitor, the two source oriented monitoring sites, and the two discontinued monitoring sites in the Central Indiana Area.

Table 3.1 Monitoring Data for the Central Indiana Area (Annual Average and 2008-2010 Design Values)

SITE ID COUNTY SITE NAME YEAR Annual Average (μg/m 3 ) 2008-2010 Design Value (μg/m 3 )

180970078 Marion IndianapolisWashington Park 2008 13.02

12.7 2009 12.11

2010 12.86

180970081 Marion Indianapolis-W 18 th
Street 2008 13.75

13.6 2009 12.96

2010 14.03

180970083 Marion Indianapolis-E. Michigan Street 2008 13.17

13.2 2009 12.40

2010 13.918 Graph 3.1 visually demonstrates the 2006 throug h 2010 design values for the Central Indiana Area.

Graph 3.1 Design Values for the Central Indiana Area, 2006 through 2010

Red line represents the annual standard for fine particles of 15 μg/m 3

. Note: The Indianapolis Mann Road and E. 75 th Street monitors were discontinued December 31, 2007. 0.00 2.00 4.00 6.00 8.00 10.00 12.00 14.00 16.00Indianapolis‐MannRoadIndianapolis‐WashingtonParkIndianapolis‐E.75thStreetIndianapolis‐W18thStreetIndianapolis‐E.MichiganStreet 2006

‐ 2008

2007

‐ 2009

2008

‐ 2010μg/m39 Graph 3.2 Central Indiana Annual Fine Particles Trends, 2006 through 2010

Red line represents the annual standard for fine particles of 15 μg/m 3

. Note: The Indianapolis Mann Road and E. 75 th Street monitors were discontinued December 31, 2007.

The design values for the Cent ral Indiana nonattainment area demonstrate that the annual NAAQS for fine particles has been attained. Ap pendix A contains the co mplete fine particles monitoring data summary for the years 2000 through 2010.

Graph 3.1 shows the trend in design values, wh ile Graph 3.2 shows the trend for annual fine particles. A comprehensive list of the design va lues for the three monito ring sites over the 2000 through 2010 period is outlined in Appendix A. Th e area's design values have recently trended downward, as emissions have declined due to programs such as the Acid Rain program and cleaner automobiles and fuels, both regionally and locally. U.S. EPA’s rule to control nitrogen oxides from specific source categories (40 CFR Parts 51, 72, 75 and 96, published on October 17, 1998 and referred to as the “NO x SIP Call”) has significantly reduced emissions from large electric generating units (EGUs), industria l boilers, and cement kilns. Indiana's NO x SIP Call Rule was adopted into the Indiana Administ rative Code (IAC) on June 6, 2001 at 326 IAC 10-3 and 326 ICA 10-4. The elevated fine particle values for 2005 are cons idered an abnormal occurrence. An analysis of meteorological conditions and mon itoring values is included in Section 7.0 and supports the conclu sion that attainment of the st andard as of 2010 is not the result of unusually favorable meteorological conditi ons. It is expected that this downward trend 11.00 12.00 13.00 14.00 15.00 16.00 17.00

2006 2007 2008 2009 2010

Indianapolis

‐ Mann Road Indianapolis

‐ Washington Park Indianapolis

‐ E. 75th Street Indianapolis

‐ W 18th Street Indianapolis

‐ E. Michigan Streetμg/m3

Year10 will persist as the above programs continue and U.S. EPA’s proposed Clean Air Transport Rule is implemented.

3.3 Quality Assurance

IDEM has quality assured all data shown in Appendix A in accordance with 40 CFR 58.10 and recorded the data in the AQS database and, thus, the data is available to the public.

3.4 Continued Monitoring

Indiana commits to continue monitoring fine part icle concentrations at the sites indicated in Table 3.1 and Appendix A. IDEM will consult w ith U.S. EPA Region V staff prior to making changes to the existing monitoring network thr ough the annual network review should changes become necessary in the future. IDEM will cont inue to quality assure the Indiana monitoring data to meet the requirements of 40 CFR 58. IDEM will enter all data into AQS on a timely basis in accordance with federal guidelines.

4.0 EMISSION INVENTORY

U.S. EPA’s Redesignation Guidance and Impl ementation Rules require the submittal of a comprehensive inventory of precursor emissions for fine particles (NO x , SO 2 , and direct PM 2.5 ) representative of the year wh en the area achieves attainment of the annual NAAQS for fine particles (base year). IDEM is using 2008 as the base year. Consis tent with the federal implementation rule for fine particles, IDEM and U.S. EPA do not consider volatile organic compounds (VOCs) or ammonia (NH 3 ) to be significant contributor s to fine particles. IDEM must also demonstrate that the improvement in air quality between the year that violations occurred and the year that attainment was achieved is based on permanent and enforceable emission reductions. Other requirements relate d to the emission inventory include: a projection of the emission inventory to a ye ar at least ten years following redesignation; a demonstration that the projected level of emi ssions is sufficient to maintain the annual standard for fine particles; and, a commitment to provide future updates of the inventory to enable tracking of emission levels during the ten year maintenance period. The following subsections address each of these requirements.

4.1 Emission Trends

Point Sources

The point source data are obtained from Indian a's emissions reporting program and are based on county point source totals. The Central Indi ana Area had a 34.21 percent (%) reduction in NO x point source emissions from 2002 to 2008. As Graph 4.7 illustrates, Central Indiana NO x emissions from electric generating units have de creased substantially dur ing this time period as well. The Central Indiana Area had a 44.59% reduction in SO 2 point source emissions from 2002 to 2008. The large decrease in SO 2 point source emissions from 2006 to 2008 is due to the shutdown of the Citizens Gas and Coke plant in I ndianapolis. A moderate increase in direct11 PM 2.5 point source emissions from 2002 to 2008 is not ed. However, this increase in direct PM 2.5 emissions is due to the fact that most companies did not submit their direct PM 2.5 emissions data in 2002, but did submit direct PM 2.5 data in the 2005/2006 emissions inventory, from which the 2008 inventory is extrapolated. Graphs 4.1, 4.2, and 4.3 demonstrate the trend in point source emissions of NO x , SO 2, and direct PM 2.5 for the Central Indiana Ar ea that generally correspond to the years of monitored values used in this redesignation petition. Graphs and data tables of emissions for the point s ource category can be found in Appendix B.

Graph 4.1 Central Indiana Area NO x Point Source Emission Trends, 2002, 2006, and 2008

Graph 4.2 Central Indiana Area SO 2 Point Source Emission Trends, 2002, 2006, and 2008 ‐ 5,000 10,000 15,000 20,000 25,000

2002 2006 2008TonsperYear

Year Nitrogen Oxides

‐ 10,000 20,000 30,000 40,000 50,000 60,000 70,000 80,000

2002 2006 2008TonsperYear

Year Sulfur Dioxide12 Graph 4.3 Central Indiana Area Direct PM 2.5 Point Source Emission Trends, 2002, 2006, and 2008

All Anthropogenic Sources

Periodic inventories, which include emissions fr om all sectors (mobile, area, nonroad, and point source), were prepared for 2002, 2005/2006, and 2008. The 2006 and 2008 data were extrapolated from the 2005 emission inventor y. Graphs 4.4, 4.5, and 4.6 show the trend in anthropogenic source emissions for th e Central Indiana Area. Regional NO x emission reductions affect fine particle levels in the Central Indiana Area far more so than NO x emission reductions within the nonattainment area itself. These emission tre nds roughly follow the years of monitored trends discussed in Sectio n 3.0. There is a downward trend in NO x emissions from 2002 to 2006 and a further decrease through 2008. The decrease in NO x can be largely attributed to the impact of the NO x SIP Call. There is a general downward trend in SO 2 emissions from 2002 to 2008, as well. As noted previously, th ere is an overall incr ease in direct PM 2.5 anthropogenic emissions. Graphs and data tables of emissions from each source category are available in Appendix C. ‐ 500 1,000 1,500 2,000 2,500 3,000

2002 2006 2008TonsperYear

Year Direct Fine Particles13 Graph 4.4 NO x Emission Trends, All Sources in the Central Indiana Area, 2002, 2006, and 2008

Graph 4.5 SO 2 Emission Trends, All Sources in the Central Indiana Area, 2002, 2006, and 2008 ‐ 10,000 20,000 30,000 40,000 50,000 60,000 70,000 80,000

2002 2006 2008TonsperYear

Year Nitrogen Oxides

‐ 10,000 20,000 30,000 40,000 50,000 60,000 70,000 80,000 90,000

2002 2006 2008TonsperYear

Year Sulfur Dioxide14 Graph 4.6 Direct PM 2.5 Emission Trends, All Sources in Central Indiana Area, 2002, 2006, and 2008

EGU Sources

Graphs 4.7 and 4.8 show both NO x and SO 2 emissions are decreasing s ubstantially in response to national programs affecting all EGUs, such as the Acid Rain program and the NO x SIP Call. Other sectors of the inventory also impact the fo rmation of fine particles, but large regional sources, such as EGUs, have a substantial imp act on the formation of fine particles.

The data were taken from U.S. EPA's Clean Air Markets database located at http://www.epa.gov/airmarkets

. Data are available sooner for these units than other point sources in the inventory because of the NO x SIP Call budget and trading requirements.

As part of the NO x SIP Call, the states were required to adopt into their rules a budget for all large EGUs. Indiana’s budget is referenced in 326 IAC 10-4. The budget represents a statewide cap on NO x emissions. Although each unit is allocated emissions based upon hi storic heat input, utilities can meet this budget by over-controlling certain units or purchasing credits from the market to account for overages at other units. To summarize, NO x emissions have dramatically decreased over the years represented on these graphs.

These emissions, capped by the state rule, are exp ected to remain near these levels throughout the maintenance period covered by this request. The state cap for the NOx SIP Call remained in place through 2008, at which time the Clean Air Inte rstate Rule (CAIR) program superseded it. ‐ 1,000 2,000 3,000 4,000 5,000 6,000

2002 2006 2008TonsperYear

Year Direct Fine Particles15 CAIR, issued in March 2005, adopted by the Indi ana Air Pollution Control Board on November 1, 2006, and implemented beginning in 2010, will continue to reduce regional EGU NO x emissions statewide by approximately another 17% by 2015 and 57% for EGU SO 2 emissions by 2015. The D.C. Circuit court’s vacatur of CAIR in July of 2008 and subsequent remand without vacatur of CAIR in December of 2008, directs U.S. EPA to revise the CAIR rule in the future. The proposed Clean Air Transport Rule (CAIR’s replacement rule) will result in similar or greater emission reductions than assumed within the current emission inventories, once it is implemented.

Graph 4.7 NO x Emissions from EGUs, Central Indiana Area, 1999 to 2009

0 2,000 4,000 6,000 8,000 10,000 12,000 14,000 16,000

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009

Nitrogen OxidesTonsperYear

Year16 Graph 4.8 SO 2 Emissions from EGUs, Central Indiana Area, 1999 to 2009

Although there are minor fluctuations in emissions over time, as shown in Graphs 4.7 and 4.8, there are moderate reductions to date. Indiana does expect to see significant reductions in SO 2 emissions from CAIR and Best Available Retr ofit Technology (BART), once implemented. Additional NO x control technologies have been inst alled on various emission units at the Indianapolis Power & Light Company (IPL)-Har ding Street Generating Station located in Marion County as well as the IPL-Eagle Valley Generating Station, locat ed in Morgan County, since the 2001-2003 monitoring period. These control technologies include selective noncatalytic reduction, selective catalytic reduction, neural net controls, low NO x burners, and separated overfire air. The SO 2 data from 2008 reflects the installation of a flue gas desulphurization system at the IPL-Harding Stre et Generating Station that became operational in 2007. As IPL indicates, many control technologies have been installed voluntarily and are not required to be operated. Most of the major sources within the area are subject to the NO x SIP Call, CAIR or RACT requirements. Appendix B shows detailed emissions for the point source emissions, and Appendix D shows detailed emissions for the EGUs. 0 10,000 20,000 30,000 40,000 50,000 60,000 70,000 80,000

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009
Sulfur DioxideTonsperYear17 Graph 4.9 Indiana Statewide NO x Emissions from EGUs, 1999 to 2009

Graph 4.10 Indiana Statewide SO 2 Emissions from EGUs, 1999 to 2009 0 50,000 100,000 150,000 200,000 250,000 300,000 350,000 400,000

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009

Nitrogen OxidesTonsperYear

0 100,000 200,000 300,000 400,000 500,000 600,000 700,000 800,000 900,000 1,000,000

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009

Sulfur DioxideTonsperYear18 4.2 Base Year Inventory

IDEM prepared a comprehensive inventory for th e Central Indiana Area, including area, mobile, nonroad, and point sources for direct PM 2.5, NO x and SO 2 for 2005/2006 and 2008 (the years with the most complete emissions inventory availabl e at this time). The 2008 emission inventory represents a base year for maintenance purpos es. The 2007 implementation rule for the annual fine particle standa rd states that NO x , SO 2, and direct PM 2.5 are the regulated precursors of fine particles. Ammonia and VOCs are not required to be addressed unless the state or U.S. EPA make a technical demonstration that emissions of these pollutants from sources in the state significantly contribute to PM 2.5 concentrations in a given nonattainment area. U.S. EPA and IDEM have not determined ammonia or VOCs ar e significant contributor s to fine particles formation in Indiana. IDEM’s 2008 base ye ar inventory was deve loped as follows:

 Area sources were extrapolated from the Indiana 2005 periodic inventory submitted to U.S. EPA.

 Mobile source emissions were calculated from MOBILE6.2 model-produced emission factors and data extrac ted from the region’s travel-dema nd model. These emissions were then interpolated as needed to determine 2008 base year values.

 Point source information was compiled from IDEM’s emissions inventory database and U.S. EPA’s Clean Air Mark ets acid rain database.

 Biogenic emissions are not specifically incl uded in these summaries, but are included in the photochemical modeling result s presented in Section 7.0.

 Nonroad emissions were extrapolated fr om the 2005 National Emissions Inventory (NEI). To address concerns about the accuracy of some of the categories in U.S. EPA’s nonroad emissions model, Lake Michig an Air Directors Consortium (LADCO) contracted with two companies to review th e base data and make recommendations. One of the contractors also estimated emissions for two nonroad categories not included in U.S. EPA's nonroad model. Emissions were estimated for commercial marine vessels and railroads. The recreational motorboa t population and spatial surrogates (used to assign emissions to each) were significantly updated. The populations for the construction equipment category were also reviewed and updated based upon surveys completed in the Midwest and the temporal al location for agricultural sources was also updated. A new nonroad estimation model was provided by U.S. EPA for the 2005 analysis.

Appendix C contains data tables a nd graphs of these emissions.

4.3 Emission Projections

In consultation with the U.S. EPA and other stakeholders, IDEM se lected the year 2025 as the maintenance year for this redesignation request . This document contai ns projected emission inventories for 2015, 2020, and 2025 for the Central Indiana Area. These emission projections were prepared by IDEM, with assistance from LADCO and the Indian apolis Metropolitan Planning Organization. The proj ected emission inventories for 2020 and 2025 were extrapolated from 2018 estimates developed by LADCO.19 The detailed 2015, 2020, and 2025 emission inventory for the Central Indiana Area can be found in Appendix E. Emission trends are an impor tant gauge for continued compliance with the annual standard for fine particles. Therefore, IDEM performed an in itial comparison of the inventories for the base year of 2005/2006, second ary validation year of 2008, interim years of 2015 and 2020, and maintenance year of 2025 for the Central Indiana Area.

The 2005/2006 LADCO modeling invent ory was used as the basis for estimated emissions for the years 2008, 2015, 2020, and 2025, using LADCO’s gr owth factors, for all sectors except point sources (electrica l generating units and non-electric generating units). Point source emissions for 2005/2006 and 2008 were compiled from Indiana’s emission inventory database. The 2006 base year and 2008 second ary validation emissions were extrapolated from the 2005 emission inventory. The 2015 interim year emi ssions were interpolat ed based on the 2009 and 2018 LADCO modeling inventory, us ing LADCO’s growth factors, for all sectors. The 2020 interim year emissions and the 2025 maintenance year emissions were extrapolated from the 2009 and 2018 LADCO modeling inventory.

Graphs 4.11, 4.12, and 4.13 visually compare 2008 NO x , SO 2, and direct PM 2.5 county total estimated emissions with the 2015, 2020, and 2025 pr ojected emissions for the Central Indiana Area. Mobile source emission i nventories are further described in Section 5.0. In addition to LADCO’s estimates, point source emissions we re projected based upon the statewide EGU NO x budgets from the Indiana NO x rule. It should be noted th at EGU emission estimates for 2015, 2020, and 2025 were projected utilizing the Depart ment of Energy Information’s Annual Energy Outlook Supplemental tables for the year 2018. Th ese tables were generated for the reference case of the Annual Energy Outlook 2007 using the National Energy Modeling System. Graphs and data tables of emissions from the EGU source category can be found in Appendix D.20 Graph 4.11 Comparison of 2005 and 2008 Estimated and 2015, 2020, and 2025 Projected NO x Emissions for the Central Indiana Area

Graph 4.12 Comparison of 2005 and 2008 Estimated and 2015, 2020, and 2025 Projected SO 2 Emissions for the Central Indiana Area ‐ 10,000 20,000 30,000 40,000 50,000 60,000

2006 2008 2015 2020 2025TonsperYear

Year Nitrogen Oxides

‐ 10,000 20,000 30,000 40,000 50,000 60,000 70,000

2006 2008 2015 2020 2025TonsperYear

Year Sulfur Dioxide21 Graph 4.13 Comparison of 2005 and 2008 Estimated and 2015, 2020, and 2025 Projected Direct PM 2.5 Emissions for the Central Indiana Area

Graph 4.14 Comparison of 2005 and 2008 Estimated and 2015, 2020, and 2025 Projected NO x , SO 2 , and Direct PM 2.5 Emission Trends for the Central Indiana Area ‐ 500 1,000 1,500 2,000 2,500 3,000 3,500 4,000 4,500 5,000

2006 2008 2015 2020 2025TonsperYear

Year Direct Fine Particles

‐ 10,000 20,000 30,000 40,000 50,000 60,000 70,000

2006 2008 2015 2020 2025TonsperYear

Nitrogen Oxides Sulfur Dioxide Direct Fine Particles22 NO x emissions within the Centra l Indiana Area are projected to decline by 44.07% between 2008 and 2025. Emission reduction benefits fr om U.S. EPA rules covering the NO x SIP Call, Tier 2 Motor Vehicle Emission Standards and Gasoline Sulfur Control Requirements, Heavy-Duty Highway Engine Rule, and the Nonroad Diesel Engine Rule are factored into the changes. Additionally, due to implementation of the NO x SIP Call across the eastern United States, NO x and fine particle levels entering the Centra l Indiana Area will also be decreased. SO 2 emissions within the Central Indiana Area are projected to declin e by 25.98% between 2008 and 2025. Direct PM 2.5 emissions from 2008 to 2025 are projected to decline by 3.11% within the Central Indiana Area. The 2015, 2020, and 2025 emission projec tions assume no additional controls will be installed. This approach ove r-predicts future year emissions as it is reasonable to assume a significant number of facilities will need to instal l additional controls to comply with CAIR or the proposed Clean Air Transport Rule.

Table 4.1 Comparison of 2008 Estimated and 2025 Project ed Emission Estimates Central Indiana Area (Tons Per Year) 2008 2025 Change % Change

NO x 50,777.76 28,399.04 -22,378.72 44.07% Decrease

SO 2 43,502.68 32,201.49 -11,301.19 25.98% Decrease

Direct PM 2.5 4,103.99 3,976.18 -127.81 3.11% Decrease

4.4 Demonstration of Maintenance

Quality-assured ambient air quality data from all the monitoring sites indicat e that air quality in the Central Indiana Area met the annual standard for fine particles for the three-year period ending in 2010. U.S. EPA’s Redesignation Guidan ce states, “A state may generally demonstrate maintenance of the NAAQS by either showing th at future emissions of a pollutant or its precursors will not exceed the level of the attain ment inventory, or by modeling to show that the future mix of sources and emission rates will not cause a violation of the NAAQS.” (Page 9) Section 3.0 of this document shows that the Central Indiana Area has in fact measured attainment for fine particles for the three consecutiv e periods ending in 2008, 2009 and 2010. Additionally, emission projections outlined in Section 4.0 of th is document clearly illustrate that regional NO x , SO 2, and direct PM 2.5 emissions in the area will continue to decline leading to local reductions between 2008 (base year) and 2025 (maintenance plan horizon). Section 7.0 further discusses the implications of these emission trends and provid es an analysis to supp ort these conclusions.

In Indiana, major point sources in all counties are required to submit air emissions information once every three years, or annually, if the SO 2 or NO x potential to emit is greater than 2 , 500 tons per year in accordance with the Emission Reporting Rule, 326 IAC 2-6. IDEM prepares a new periodic inventory for all precurs or emission sectors every three y ears. These precursor emission inventories will be prepared for 2011, 2014 and 2017, as necessary, to comply with the inventory reporting requirements established in the CAA. Emissions information will be compared to the 2008 base year and the 2025 projected maintenance y ear inventories to asse ss emission trends, as necessary, to assure continued compliance with the annual standard for fine particles.23 4.5 Permanent and Enforceable Emission Reductions

Permanent and enforceable reductions of NO x and SO 2 have contributed to the attainment of the annual standard for fine particles. Some of th ese reductions were due to the implementation of the NO x SIP Call rule, and some were due to the application of tight er federal standards on motor vehicles and fuels.

Section 6.0 identifies the emission control measures specific to the Central Indiana Area, as well as the implementation status of each measure.

4.6 Provisions for Future Updates

As required by Section 175A(b) of the CAA, Indi ana commits to submit to the Administrator, eight years after redesignation, an additional revi sion of this SIP. Th e revision will contain Indiana's plan for maintaining the national primary fine particles air quality standard for ten years beyond the first ten-year pe riod after re designation.

5.0 TRANSPORTATION CONFORMITY BUDGETS

U.S. EPA requirements outlined in 40 CFR 93.118( e)(4) stipulate that mobile source emission budgets for direct PM 2.5 and NO x be established as part of a SIP. The motor vehicle emission budgets (MVEBs) are necessary to demonstrat e conformance of transportation plans and improvement programs with the SIP.

5.1 Onroad Emission Estimates

The Indianapolis Department of Metropolit an Development (DMD), the Madison County Council of Governments (MCCOG), and th e Columbus Area Metropolitan Planning Organization are the Metropolitan Planning Organizations (MPOs), whose planning areas intersect the five county Cent ral Indiana Area. In additi on, significant portions of the nonattainment area are not under th e jurisdiction of any MPO. These planning areas in relation to the counties in the PM 2.5 nonattainment area are il lustrated in Figure 5.1.

An interagency consultation group consisting of representatives from the three MPOs, the Indiana Department of Transportation, IDEM, the Federal Highway Ad ministration, and local transit and environmental quality providers join tly determine regional significance. Primary responsibility for modeling emissions falls under the purview of DMD, which runs the MOBILE6.2 model to arrive at emission rates, an d its regional travel model to develop estimates of vehicle miles traveled (V MT) for all areas, except for the MCCOG planning area, which administers its own travel model. DMD then compiles all results into a regional emissions analysis, which all MPOs then adop t following a public involvement period.24 Figure 5.1 Central Indiana Metropolitan Planning Organization (MPO) Jurisdictions

These models simulate the traffic in the area and are used to predict what the traffic would be like in future years given growth expectations. The models are used mostly to identify where travel capacity will be needed and to determine the infrastructure requirements necessary to meet that need. They are also used to support the calculati on of mobile source emissions. The travel demand forecast model is used to predict the total daily VMT and the U.S. EPA software program, MOBILE6.2, is used to calculate per mile emissions. The produc t of these two outputs, once combined, is the estimated total amount of pollution emitted by the onroad vehicles for the area analyzed.25 5.2 Overview

Broadly described, MOBILE6.2 is used to determ ine “emission factors”, which are the average emissions per mile (grams/mile) for fine particles and fine particle precursors, including direct PM 2.5 , NO x and SO 2 . There are numerous variables that can affect the emission factors. The vehicle-fleet (vehicles on the road) age and the vehicle types have a major effect on the emission factors. The facility-type on which the vehicl es are traveling (MOBILE6.2 facility-types are Freeway, Arterial, Local, and Ramp) and the vehi cle speeds also affect the emission factor values. Meteorological factors such as air temperature and humi dity affect emission factors as well. These data are estimated using the best available data to create emission factors for fine particle precursors including direct PM 2.5 , NO x and SO 2 . After emission factors are determined, they must be multiplied by the VMT to determine the quantity of vehicle-related emissions. This information is derived from the travel demand model.

It should be noted that each year analyzed will have different emission factors, volumes, speeds, and likely results in additional modeling. MO BILE6.2 input and output files are found in Appendix F.

5.3 Analysis Years

The travel demand model contains road networks that are time specific. The Central Indiana MPOs have modeled the years 2002, 2010, 2015, a nd 2025. Information, including emissions, has been interpolated from 2002 and 2010 for the years 2005, 2006, and 2008 and from 2015 and 2025 for the year 2020. This Redesignation Petiti on provides emission inventory estimates for 2002, 2005, 2006, 2008, 2015, 2020, and 2025 to meet the requirements specified by the CAA and U.S. EPA. The emission estimates outlined in Section 4.0 of this document reference the mobile source emissions data contained in Table 5.1.

5.4 Emission Estimates

Table 5.1 outlines onroad emission estimates for the entire nonattainment area for the years 2002, 2005, 2006, 2008, 2015, 2020, and 2025.

Table 5.1 - Emission Estimates for Onroad Mobile Sources 2002 2005 2006 2008 2015 2020 2025 VMT (thousand miles/day) 52,979.53 49,540.45 48,394.10 46,101.38 46,614.09 49,355.27 52,096.44

PM 2.5 (tons/year) 670.50 423.11 416.63 403.67 289.67 275.11 260.54

NO x (tons/year) 38,059.50 23,354.20 22,734.38 21,494.74 12,259.66 9,752.70 7,245.7426 5.5 Motor Vehicle Emission Budget

Table 5.2 contains the motor vehi cle emissions budget for the entire nonattainment area for the years 2015 and 2025. These MVEBs are intended to be direct replacements of those provided in Indiana’s previous submittal.

Table 5.2 – Motor Vehicle Emission Budgets (Tons Per Year)
Year 2015 2025

PM 2.5 353.40 317.86

NO x 14,956.79 8,839.80

Consistent with the federal implementation rule for fine particles, Indiana does not consider mobile source SO 2 to be a significant contributor to fine particles for this nonattainment area, as mobile source SO 2 constitutes less than 1.2% of the ar ea’s total anthropogenic emissions.

These budgets include emission estimates calculated for 2015 and 2025. The emission estimates are derived from the MPO’s travel demand models and MOBILE6.2, as described above. Through the interagency consultation process, it was determined that an interim budget year of 2015, in addition to the horizon year budget of 2025, would be appropriate. A reasonable margin of safety has been applied to the 2015 a nd 2025 budgets in the amount of 22% for both PM 2.5 and NO x . Margins of safety are used to accommodate th e wide array of assumptions that are factored into the calculation process. Since assumptions change over time, it is necessary to have a margin of safety that will accommodate the im pact of refined assumptions in the process.

The rule at 40 CFR 93.101 defines safety marg in as the amount by which the total projected emissions from all sources of a given pollutant ar e less than the total emissions that would satisfy the applicable requirement for reasonable furthe r progress, attainment, or maintenance. When compared to the overall safety margin as de fined by 40 CFR 93.101, it is ev ident this allocation to mobile sources is significantly below the total safety margin for all sources in the Central Indiana Area as detailed in Table 4.1.

5.6 Commitment to Amend Motor Vehicle Em ission Budgets Using Motor Vehicle Emission Simulator (MOVES)

On March 2, 2010, U.S. EPA published a Notice of Availability for the Motor Vehicle Emission Simulator (MOVES) model. IDEM is committed to submitting a revision to the MOBILE6.2 developed MVEBs using the MOVES model as s oon as possible and well in advance of the March 2, 2012, expiration of the transportation c onformity “grace period.” IDEM recognizes that U.S. EPA will allow the MOBILE6.2 budgets to be replaced through an adequacy notice in place of a full publication to the Federal Register.

All methodologies, latest planning assumpti ons, margins of safety, and MOVES model commitments were determined appropriate through the intera gency consultation
process.27 6.0 CONTROL MEASURES AND REGULATIONS

This section provides specific information on the control measures that have been or will be implemented in the Central Indiana Area, includ ing CAA requirements and additional state or local measures implemented beyond CAA requirements.

6.1 Reasonably Available Control Technology (RACT)

As required by Section 172 of the CAA, in the mid-1990s, Indiana promulgated rules requiring RACT for emissions of VOCs. There were no specific rules required by the CAA, such as RACT for existing sources, beyond st atewide rules. Statewide RACT rules have applied to all new sources locating in Indiana since that time. The Indiana rules are found in 326 IAC 8. The following is a listing of applicable rules:

326 IAC 8-1-6 BACT fo r Non-Specific Sources 326 IAC 8-2 Surface Coating Emission Limitations 326 IAC 8-3 Solvent Degreasing Operations 326 IAC 8-4 Petroleum Sources 326 IAC 8-5 Miscellaneous Operation 326 IAC 8-6 Organic Solvent Emission Limitations

Since the Central Indiana Area attained the annua l standard for fine particles prior to an Attainment SIP or RACT SIP being due, and sin ce the Implementation Rule for fine particles stipulates that states are only required to draft and implemen t RACT rules for the precursor emission reductions necessary to attain the sta ndard, no further RACT rules are required for this area. These Indiana rules are CAA requirement s already in the SIP and provide secondary benefits for PM 2.5
. 6.2 Implementation of Past SIP Revisions

The area was only recently designat ed nonattainment for the annual st andard for fine particles in 2003 and the area has now attained the standard well in advance of its attainment deadline of 2010. As a result, Indiana is no longer required to develop and submit an Attainment SIP or RACT SIP for this area under the an nual NAAQS for fine particles.

6.3 Nitrogen Oxides Rule

The U.S. EPA NO x SIP Call required twenty-two states to adopt rules that would result in significant emission reductions from large EGUs, industrial boilers, and cement kilns in the eastern United States. The Indiana rule was adopted in 2001. Beginning in 2004, this rule accounts for a reduction of a pproximately 31% of all NO x emissions statewide compared to previous uncontrolled years.

Twenty-one other states have also adopted these rules. The resu lt is that significant reductions have occurred regionally and within the nonattai nment area because of th e number of affected units within the region. From Gr aphs 4.7, it can be seen that em issions covered by this program28 have been trending downward since 1999. Table 6.1, compiled from data taken from the U.S. EPA Clean Air Markets web s ite, quantifies the gradual NO x reductions that have occurred in Indiana as a result of Title IV (Acid Rain) of the CAA and the NO x SIP Call Rule. The NO x SIP Call cap stayed in place through 2008, at which ti me the caps in the CAIR program superseded it. Since CAIR is a regional cap and trade prog ram, it cannot be predicted at this time what effect this will have on EGU units located in th e nonattainment area or other upwind counties.

Further, U.S. EPA published Phase II of the NO x SIP Call that established a budget for large (emissions of greater than 1 ton pe r day) stationary internal combus tion engines. In Indiana, the rule decreases emissions statewide from natural gas compressor stations by 4,263 tons during the ozone season (April through Septem ber). The Indiana Phase II NO x SIP Call Rule became effective February 26, 2006, and im plementation began in 2007.

Table 6.1 Trends in EGU NO x Emissions Statewide in Indiana

Year NO x Emissions (tons/year) 1999 347,216.5 2000 334,522.1 2001 315,419.7 2002 281,146.1 2003 260,980.0 2004 224,311.3 2005 207,981.6 2006 202,728.0 2007 196,553.1 2008 196,134.5 2009 110,968.9 Budget 2009-2014 108,935 Budget 2015 and later 90,779

6.4 Measures Beyond Clean Air Act SIP Requirements

Reductions in fine particles precurs or emissions have occurred, or are anticipated to occur, as a result of local and federal programs. These additional control measures include those listed in this section.

Tier 2 Vehicle Standards 1

Federal Tier 2 motor vehicle sta ndards require all passe nger vehicles in a manufacturer’s fleet, including light-duty trucks and s port utility vehicles (SUVs), to meet an average standard of 0.07 grams of NO x per mile. Implementation began in 2004 and was completed in 2007. The Tier 2

1 http://www.epa.gov/fedrgstr/EPA-AIR /2000/February/Day-10/a19a.htm29 standards also cover passenger vehicles over 8,500 pounds gross vehicle weight rating (larger pickup trucks and SUVs), which are not covered by the current Tier 1 standards. For these vehicles, the standards were phased in begi nning in 2008, with full compliance in 2009. The new standards require vehicles to be 77% to 95 % cleaner than those on the road prior to the program. The Tier 2 standards also reduced the sulfur content of gasoline to 30 parts per million (ppm) beginning in January 2006. Most gasoline sold in Indiana prior to January 2006 had a sulfur content of about 500 ppm. Sulfur occurs naturally in gasoline, but interferes with the operation of catalytic converters on vehicles resulting in higher NO x emissions. Lower sulfur gasoline is necessary to achieve the Tier 2 vehicle emission standards.

Heavy-Duty Gasoline and Dies el Highway Vehicle Standards 2

New U.S. EPA standards designed to reduce NO x and VOC emissions from heavy-duty gasoline and diesel highway vehicles took effect in 2004. A second pha se of standards and testing procedures, that began in 2007, reduced fine part icles from heavy-duty highway engines and also reduced highway diesel fuel su lfur content to 15 ppm since th e sulfur can damage emission control devices. The total program is expect ed to achieve a 90% reduction in direct PM 2.5 emissions and a 95% reduction in NO x emissions for these new engi nes using low sulfur diesel, compared to existing engines using higher sulf ur content diesel. There will also be SO 2 reductions from these rules. U.S. EPA ha s not quantified the expected reductions.

Large Nonroad Diesel Engine Standards 3

In May 2004, U.S. EPA promulgated new rules for large nonroad diesel engines, such as those used in construction, agricultur al, and industrial equipment, to be phased in between 2008 and 2014. The nonroad diesel rules also reduce the al lowable sulfur in nonroad diesel fuel by over 99%. Prior to 2006, nonroad diesel fuel averaged approximately 3,400 ppm sulfur. This rule limited nonroad diesel sulfur content to 500 ppm by 2006, with a further reduction to 15 ppm by 2010. The combined engine and fuel rules will reduce NO x and PM emissions from large nonroad diesel engines by over 90%, compared to current nonroad engines using higher sulfur content diesel.

Nonroad Spark-Ignition Engines and Recreational Engine Standards

This new standard, effectiv e in July 2003, regulates NO x , VOCs, and carbon monoxide (CO) for groups of previously unregulated nonroad engines. The new standard applies to all new engines sold in the United States and imported after the st andards went into effect . The standard applies to large spark-ignition engines (forklifts and airport ground se rvice equipment), recreational vehicles (off-highway motorcycle s and all-terrain vehicles), a nd recreational marine diesel engines. The regulation varies based upon the type of engine and vehicle.

The emissions from large spark-ignition engines contribute to ozone form ation and ambient CO and PM 2.5 levels in urban areas. Tier 1 of this standard was implemented in 2004 and Tier 2 started in 2007. Like the large spark-ignition engines, emissions from recreational vehicles

2 http://www.epa.gov/fedrgstr/EPA-AIR /1997/October/Day-21/a27494.htm
3 http://www.epa.gov/fedrgstr/EPA-AIR /1998/October/Day-23/a24836.htm30 contribute to ozone and fine partic les formation and ambient CO and PM 2.5 levels. For Model Year 2006 off-highway motorcycles and all-terrain vehicles, at least 50% of a manufacture’s fleet was required to meet the new exhaust emissions standard and 100% of the fleet was required to meet the standards in 2007. Recreati onal marine diesel engines over 37 kilowatts are used in yachts, cruisers, and ot her types of pleasure cr aft. Emissions from recreational marine engines contribute to ozone formation and PM levels, especially surrounding marinas.

When all of the nonroad spark- ignition engines and recreationa l engine standards are fully implemented, an overall 72% reduc tion in VOC, 80% reduction in NO x, and 56% reduction in CO emissions are expected by 2020.

Reciprocating Internal Co mbustion Engine Standards 4

This new standard, effective in May 2010, regulat es emissions of air toxics emissions from existing diesel powered stationary reciprocating internal combusti on engines that meet specific site rating, age and size criteria. These engines are typically used at i ndustrial facilities (e.g. power, chemical, and manufacturing plants) to ge nerate electricity for compressors and pumps and to produce electricity to pum p water for flood and fire co ntrol during emergencies.

The standard applies to stationary diesel engine s: (1) used at area sources of air toxics and constructed or reconstructed befo re June 12, 2006; (2) used at majo r sources of air toxics, having a site rating of less than or e qual to 500 horsepower, and constr ucted or reconstructed before June 12, 2006; and (3) used at major sources of air toxics for non-emergency purposes, having a site rating of greater than 500 horsepower, and constructed or reconstructed before December 19, 2002.

Operators of existing engines will be required to: (1) install em issions control equipment that would limit air toxics up to 70% for stationary non-emergency engi nes with a site rating greater than 300 horsepower; (2) perform emission test s to demonstrate engine performance and compliance with rule requirements; and (3) bur n ultra-low sulfur fuel in stationary nonemergency engines with a site rati ng greater than 300 horsepower.

When all of the reciprocating internal combustion engine standards are fully implemented in 2013, U.S. EPA estimates that emissions from these engines will reduce air toxics by approximately 1,000 tons per year (tpy), PM 2.5 by 2,800 tpy, CO by 14,000 tpy, and VOC by 27,000 tpy.

Category 3 Marine Diesel Engine Standards 5

This new standard, effective in June 2010, pr omulgates more stringent exhaust emission standards for new large marine diesel engines with per-cylinder displacement at or above 30 liters (commonly referred to as Category 3 compre ssion-ignition marine engines) as part of a coordinated strategy to address em issions from all ships that affect U.S. air quality. These emission standards are equivalent to those adop ted in the amendments to Annex VI to the

4 http://www.epa.gov/ttn/atw/rice/fr03mr10.pdf
5 http://www.regulations.gov/s earch/Regs/home.html#documen tDetail?R=0900006480ae43a631 International Convention for the Prevention of Pollution from Ships (MARPOL Annex VI). The emission standards apply in two stages—near-term standards for newly built engines will apply beginning in 2011; long-term standard s requiring an 80% reduction in NO x emissions will begin in 2016.

U.S. EPA is adopting changes to the diesel fuel program to allow for the production and sale of diesel fuel with up to 1,000 ppm sulfur for use in Category 3 marine vessels. The regulations generally forbid production and sale of fuels with more than 1 ,000 ppm sulfur for use in most U.S. waters, unless operators achieve equivale nt emission reductions in other ways.

U.S. EPA is also adopting provisions to apply some emission and fuel standards to foreignflagged and in-use vessels that ar e covered by MARPOL Annex VI.

When this strategy is fully implemen ted in 2030, U.S. EPA estimates that NO x and PM 2.5 emissions in the U.S. will be reduced by approximately 1.2 million tpy and 143,000 tpy, respectively.

Clean Air Interstate Rule (CAIR)

On May 12, 2005, U.S. EPA promulgated the “Rule to Reduce Interstate Transport of Fine Particulate Matter and Ozone (C lean Air Interstate Rule); Revisions to Acid Rain Program; Revisions to the NO x SIP Call”; Final Rule (70 FR 25162). Th is rule established the requirement for states to adopt rules limiting the emissions of NO x and SO 2 and provided a model rule for the states to use in developing thei r rules to meet federal requirements. The purpose of CAIR was to reduce interstate transport of precurs ors to fine particles and ozone.

CAIR applied to: (1) any stationary, fossil-fuel -fired boiler or stati onary, fossil-fuel-fired combustion turbine, a generator w ith a nameplate capacity of more than 25 megawatt electrical (MWe) producing electricity for sale; and (2) a unit that qualifies as a cogeneration unit during the 12-month period starting on the da te that the unit first produces electricity and continues to qualify as a cogeneration unit, a cogeneration unit serving at any time a generator with a nameplate capacity of more than 25 MWe and s upplying in any calendar year more than onethird of the unit’s potentia l electric output capacity or 219,000 megawatt hours (MWh), whichever is greater, to any utility power distribu tion system for sale.

This rule provides annual state caps for NO x and SO 2 in two phases, with the Phase I caps for NO x and SO 2 starting in 2009 and 2010, respectively. Ph ase II caps become effective in 2015. U.S. EPA is allowing the caps to be met through a cap and trade program if a state chooses to participate in the program.

In response to U.S. EPA’s rulemaking, IDEM a dopted a state rule in 2006 based on the model federal rule. IDEM’s rule includes annual and seasonal NO x trading programs, and an annual SO 2 trading program. This rule requir es compliance effective January 1, 2009.

SO 2 emissions from power plants in the 28 eastern states and the District of Columbia covered by CAIR will be cut by 4.3 million tons by 2009 and reduced by an additional 5.4 million tons in32 2015. NO x emissions will be cut by 1.7 million tons by 2009 and reduced by an additional 1.3 million tons in 2015. The D.C. Circuit court’s va catur of CAIR in July of 2008 and subsequent remand without vacatur of CAIR in December of 2008 directs U.S. EPA to revise or replace CAIR in order to properly address the deficiencies outlined by the court.

Since the court’s opinion made it clear that CAIR is deficient and must be revised or replaced, the program cannot be defined as permanent a nd enforceable for SIP purposes. On July 6, 2010, U.S. EPA proposed the Clean Air Transport Rule to replace CAIR. The Clean Air Transport Rule will result in even further benefits above and beyond CAIR than what is assumed within the emission inventories and modeling.

Together, these rules will substantially reduce local and regional sour ces of fine particle precursors. The modeling analyses discussed in Section 7.0 include thes e rules and show the reductions in annual fine particle concentrations expected to result from the implementation of these rules.

6.5 Controls to Remain in Effect

IDEM commits to maintain the control measures listed above after redesignation, or submit to U.S. EPA, as a SIP revision, any changes to its rules or emission limits applicable to SO 2 , NO x, or direct PM 2.5 sources as required for maintenance of the annual standard for fine particles in the Central Indiana Area.

Indiana, through IDEM’s Office of Air Quality and its Compliance and Enforcement Branch, has the legal authority and necessary resources to act ively enforce any violations of its rules or permit provisions. After redesignati on, it intends to continue enforci ng all rules that relate to the emission of fine particles and fine partic le precursors in the Central Indiana Area.

6.6 New Source Review Provisions

Indiana has a long standing and fully implemente d New Source Review (NSR) program that is outlined in rule at 326 IAC 2. The rule include s provisions for the Prevention of Significant Deterioration (PSD) permitting program in 326 IAC 2-2 and the emissions offset rule in 326 IAC 2-3. Indiana's PSD program was conditionally approved on March 3, 2003 (68 FR 9892) and received final approval on May 20, 2004 (69 FR 29071) by U.S. EPA as part of the SIP.

Any emission unit that is not lis ted in the 2005 emission inventor y, or for which credit through the shutdown or curtailment of operations was taken in demonstrating attainment, will not be allowed to construct, reopen, modify, or recons truct without meeting all applicable permit rule requirements. The review process will be identical to that used for new sources. Once the area is redesignated, OAQ will implement NSR through the PSD program, which requires an air quality analysis to evaluate whethe r the new source will threaten the NAAQS.33 7.0 MODELING AND METEOROLOGY

Although U.S. EPA’s Redesignation Guidance do es not require modeling for nonattainment areas seeking redesignation, exte nsive modeling has been performed for the Central Indiana Area to determine the effect of national emission cont rol strategies on fine pa rticle levels. These modeling analyses determined that the Centra l Indiana Area, including Hamilton, Hendricks, Johnson, Marion, and Morgan counties are significan tly impacted by regional transport of fine particles and its precursors, and that regional SO 2 and NO x reductions are an effective way to attain the annual standard for fine particles in this area. Future year modeled annual fine particle concentrations are expected to be reduced by 2% to 10% from baseline de sign values. Examples of these modeling analyses are described in this section and can also be found in Appendix H.

7.1 Summary of Modeling Results to Support Rulemakings

U.S. EPA Modeling for Clean Air Transport Rule 2010 6

U.S. EPA performed modeling to support the emission reductions associated with the proposed Clean Air Transport Rule. U.S. EPA used the Comprehensive Air Qualit y Model with Extension (CAMx, version 5), applied to the 2005 mete orology, as processed by the Mesoscale Model (MM5), version 3.7.4. Emissions input into CAMx included SO 2 , NO x , VOCs, NH 3 , and direct PM 2.5 for 2005. The modeling was based on the annua l fine particle design values calculated from 2003 through 2005, 2004 through 2006, and 2005 through 2007. Future year modeling was conducted, which included the Central Indiana Ar ea, and the future year design values for 2012 and 2014 were evaluated for attainment of th e annual NAAQS for fine particles of 15 μg/m 3 , as shown in Table 7.1. Fine particle concentratio ns are accounted for by modeling both the base future year emissions and then the emission reductions associated with the Clean Air Transport Rule. U.S. EPA found model performance met s uggested benchmark performance goals within or close to the ranges found in othe r comparable modeling applications.

Table 7.1 Clean Air Transport Rule Modeli ng Results from U.S. EPA – 2010

County Monitor ID Design Value 2003-2007

(μg/m 3 ) Future Design Value 2012 Base

(μg/m 3 ) Future Design Value 2014 Base

(μg/m 3 )

Madison 180950009 13.96 13.80 13.35 Marion 180970042 14.24 14.26 13.78 Marion 180970078 15.26 15.18 14.69 Marion 180970079 14.71 14.61 14.12 Marion 180970081 16.05 15.93 15.43 Marion 180970083 15.90 15.77 15.27

6 http://www.epa.gov/airquality/transp ort/pdfs/TR_AQModeling_TSD.pdf34 Modeling results show that the base future year modeling with emi ssion reductions from the Clean Air Transport Rule will account for a 0.2 μg/m 3 decrease in concen trations for 2012, as well as a 0.5 to 0.6 μg/m 3 decrease in concentrations fo r 2014 in Marion and Madison counties within the Central Indiana Area.

While results of U.S. EPA’s Clean Air Transport Rule modeling indicate modeled concentrations above the standard using base case emi ssions at the Washington Park, West 18 th Street, and East Michigan Street PM 2.5 monitoring sites, it should be noted that the base year design value used by U.S. EPA was taken from 2003 through 2007 and is higher than current 2006 through 2010 design values in the area. Graph 7.1 shows the downward trend of the design values from 2000 through 2010 for the PM 2.5 monitors in the Central Indiana Ar ea. In fact, all design values for the Central Indiana Area are below th e annual NAAQS for fine particles.

Graph 7.1 PM 2.5 Design Value Trends for the Central Indiana Area: 2000 – 2010

The decrease of the 2003-2007 design value comp ared to the 2006-2010 design value at the Washington Park PM 2.5 monitor is 1.74 μg/m 3 with all the area’s PM 2.5 monitor design values decreasing from 1.73 μg/m 3 to 2.10 μg/m 3 . Therefore, U.S. EPA’s Clean Air Transport Rule modeling, using current 2006 through 2010 design values, shows all modeled concentrations well below the annual fine particle standard of 15.0 μg/m 3 , as seen in Table 7.2. 12.0 13.0 14.0 15.0 16.0 17.0

00

‐ 04 01

‐ 05 02

‐ 06 03

‐ 07 04

‐ 08 05

‐ 09 06

‐ 10Concentrations(ug/m3)

Design Value Years

Anderson Mann Road Washington Park E. 75th St.

W. 18th St. E. Michigan St. Annual Standard35 Table 7.2 Clean Air Transport Rule Modeli ng Results from U.S. EPA – 2010 (using 2006-2010 design values)

County Monitor ID Design Value 2006-2010

(μg/m 3 ) Future Design Value 2012 Base

(μg/m 3 ) Future Design Value 2014 Base

(μg/m 3 )

Madison 180950009 12.23 12.09 11.70 Marion 180970042 a N/A N/A Marion 180970078 13.52 13.45 13.02 Marion 180970079 a N/A N/A Marion 180970081 14.18 14.07 13.63 Marion 180970083 13.80 13.69 13.26

a Site was discontinued in 2007 N/A Not available

Results of the U.S. EPA’s Clean Air Transport Rule modeling show that all Central Indiana counties would attain the annua l fine particle NAAQS in 2012 with modeled impacts reduced by 1%, and will remain below 15 μg/m 3 . With further reductions projected in the Clean Air Transport Rule for 2014, all design values decrease by 3% to 4% and the area will continue to attain the annual NAAQS for fine particles.

LADCO Modeling for Clean Ai r Interstate Rule (CAIR)

LADCO conducted modeling to determine the imp act of CAIR in the Midwest. LADCO’s modeling used the CAMx model applied to the year 2005 meteorology, as processed by the MM5. Emissions input into CAMx included SO 2 , NO x , VOCs, NH 3 , and direct PM 2.5 for 2005. The modeling was based on 2003 through 2007 design values. Future year modeling for 2012 and 2018 was conducted and the future year design values were determined without the emission reductions associated with CAIR (Round 6), as shown in Table 7.3. The Clean Air Transport Rule is expected to provide reductions above and beyond CAIR.

Table 7.3 LADCO Round 6 Modeling Results for Annual PM 2.5 – Without the Clean Air Interstate Rule Emission Reductions (Using 2003 – 2007 Design Values)

Monitor ID Monitor Name County Design Value 2003-2007

(μg/m 3 ) Base-case 2012 (μg/m 3 ) Base-case 2018 (μg/m 3 )

180950009 Anderson Madison 14.0 12.9 12.6 180970042 Mann Road Marion 14.2 13.2 12.9 180970078 Washington Park Marion 15.3 14.2 13.9 180970079 E. 75 th St. Marion 14.7 13.6 13.2 180970081 W. 18 th St. Marion 16.1 14.9 14.6 180970083 E. Michigan St. Marion 15.9 14.8 14.536 Results of the LADCO Round 6 modeling show th at the Central Indiana Area will attain the annual NAAQS for fine particles by 2012. As show n in Table 7.3, future year modeled annual fine particle concentrations for 2012 will be 7% to 8% lower than baseline annual fine particle design values, and 9% to 10% lower in 2018 a nd will continue to decrease thereafter.

A graphical representation is shown in Graph 7.2. The Mann Road and E. 75 th Street monitors were shut down at the end of 2007. However, at the time the modeling was conducted, both monitors were still in operation and th erefore are included in this analysis.

Graph 7.2 LADCO Modeling Results for Central Indiana PM 2.5 Monitors for 2012 and 2018

7.2 LADCO Round 5 Speciated Mode led Attainment Test Results

The Speciated Modeled Attainment Test (SMAT) is the attainment test for annual fine particles. To determine the future year annual fine particle concentrations, speciated data is calculated. The different species that were modeled and are a ssociated with fine particles include sulfates, nitrates, organic carbon, elemental carbon, a mmonium, particle bound water, “other” primary inorganic fine particles, and pa ssively collected mass. The SM AT results from LADCO’s Round 5 modeling are listed below. Round 5 modeled the emission reduc tions associated with CAIR, so the results reflect the impact s from CAIR. Percent ranges of the model re sults from the five fine particle monitors in Centra l Indiana were broken down into the speciated constitu ents of fine particle emissions. The percent change from the observed speciat ed data in 2005 to the future year modeled results are listed in Table 7.4. Wh ile these modeling results are outdated, this 12.0 13.0 14.0 15.0 16.0 17.0 18.0

2005 2012 2018PM2.5 Concentrations (ug/m3)

Modeled Year

Anderson Mann Road Washington Park E. 75th St.

W. 18th St. E. Michigan St. Annual Standard37 weight of evidence demonstration shows the redu ction potential from national emission control measures for the PM 2.5 species in Central Indiana. An upda ted analysis will be conducted at a later time, using more current emissions and meteor ological data and for a relevant future year projection.

Table 7.4 LADCO Round 5 SMAT Modeling Results for Central Indiana

(Percent decrease from observed to modeled concentrations)

Species of PM 2.5 2009 Sulfates 23% - 26% Nitrates 0% - 6% Organic Carbon 0% - 3% Elemental Carbon 17% Ammonium 16% - 19% Particle Bound Water 19% - 24%

The results demonstrate that sulfate, ammonium, elemental carbon, and particle bound water concentration decreases are projec ted to be at least 16% in 20 09. Lesser nitrate reductions are projected to occur, up to 6%, with organic carbon reductions up to 3%. LADCO modeling shows good performance for sulfates and elemen tal carbon predicted baseline concentrations, slight over-prediction for n itrate concentrations, and under-p redictions of organic carbon concentrations. Overall, mode l performance is adequate for SIP planning and gives a good idea of the effects of emission reductions from na tional emission control measures on the Central Indiana Area.

7.3 LADCO Round 5 Particulate Source Apportionment Results

Particulate Source Apportionment (PSAT) modeli ng was conducted by LADCO. The results of the PSAT Round 5 modeling show the regional contributions by emission sectors on each monitor that was modeled. Chart 7.1 displays the PSAT modeling results for the E. Michigan Street fine particles monitor in Marion County. Indiana was the biggest regional contributor to the E. Michigan Street fine particles monitor. Illinois, Ohio, and the Visibility Improvement State and Tribal Association of the South east (VISTAS) Regional Planning Organization (Alabama, Florida, Georgia, Kentucky, Mississipp i, North Carolina, South Carolina, Tennessee, Virginia and West Virginia and the Eastern Band of the Cherokee Indians) also contributed.

The PSAT Round 5 modeling results indicate the majority of Indiana’s emission sector contributions to fine particle concentrations come from E GUs, ammonium emission sources, mobile, off-road (including marine, aircraft a nd railroad), area, and non-EGU sources. These results are considered to be representative of the entire Central Indiana Area as EGU, ammonium, and non-EGU emissions impact the entire area.38 Chart 7.1 Regional/Emission Sector PSAT Results by Sector for Marion County at E. Michigan Street PM 2.5 Monitor

Chart 7.2 displays the modeled pollu tant contributions on the E. Mi chigan Street fine particles monitor. The PSAT modeling resu lts show the majority of Indi ana’s pollutant contributions come from ammonium, nitrate, sulfate, elemental carbon, primary fine particles and organic carbon. Pollutant contributions fr om other regions consist mainly of sulfates and nitrates.

Chart 7.2 Regional/Pollutant PSAT Results by Contri bution for Marion County at E. Michigan Street PM 2.5 Monitor39 The following pie charts depict the contributions by species to fine particle concentrations at the Central Indiana Area monitors. The pie charts include both the observe d 2005 contributions and 2009 modeled contributions for each monitor. Since the monitors are in close proximity to each other, results are fairly similar in the distribut ion of species concentra tions among the monitors. Charts 7.3 through 7.7 cover the fine particle monito rs in the Central Indian a Area that are used to determine compliance with the annual NAAQS for fine particles.

The speciation listed in the pie charts include SO 4 – sulfate mass, NO 3 – nitrate mass, OC – organic carbon mass, EC – elemental carbon mass, Soil – crustal material mass, NH 4 – ammonium mass, PBW – partic les bound water mass, and BLAN – passively collected mass.

Chart 7.3 Modeled Contributions by Species to W. 18 th Street PM 2.5 Monitor in Marion County (Base Year Modeled Concentrations = 15.6 μg/m 3 ) (Future Year Modeled Concentrations =13.2 μg/m 3 )

Chart 7.4 Modeled Contributions by Sp ecies to Washington Park PM 2.5 Monitor in Marion County (Base Year Modeled Concentrations = 14.7 μg/m 3 ) (Future Year Concentrations =12.6 μg/m 3 )

2005 Modeled Contributions at W. 18th St. PM2.5 Monitor

so4 33%

no3 10%

oc 22% ec 4% soil 3% nh4 14% pbw 11% blan 3%

so4

no3

oc

ec
soil

nh4 pbw

blan 2009 Modeled Contributions at W. 18th St. PM2.5 Monitor

so4 27%

no3 12%

oc 26% ec 4% soil 4%

nh4 13% pbw 10% blan 4%

so4

no3

oc

ec
soil

nh4 pbw

blan

2005 Modeled Contributions at Washington Park PM2.5 Monitor

so4 32%

no3 11%

oc 22% ec 4% soil 3% nh4 14% pbw 11% blan 3%

so4

no3

oc

ec
soil

nh4 pbw

blan 2009 Modeled Contributions at Washington Park PM2.5 Monitor

so4 28%

no3 12%

oc 25% ec 4% soil 4% nh4 13% pbw 10% blan 4%

so4

no3

oc

ec
soil

nh4 pbw

blan40 Chart 7.5 Modeled Contributions by Species to E. 75th Street PM 2.5 Monitor in Marion County (Base Year Modeled Concentrations = 14.2 μg/m 3 ) (Future Year Modeled Concentrations =12.3 μg/m 3 )

Chart 7.6 Modeled Contributions by Species to Mann Road PM 2.5 Monitor in Marion County (Base Year Modeled Concentrations = 13.7 μg/m 3 ) (Future Year Modeled Concentrations =11.9 μg/m 3 )

Chart 7.7 Modeled Contributions by Species to E. Michigan Street PM 2.5 Monitor in Marion County

(Base Year Modeled Concentrations = 15.4 μg/m 3 ) (Future Year Modeled Concentrations =13.2 μg/m 3 ) 2005 Modeled Contributions at E. 75th St. PM2.5 Monitor

so4 31%

no3 11%

oc 23% ec 4% soil 3%

nh4 13% pbw 11% blan 4%

so4

no3

oc

ec
soil

nh4 pbw

blan 2009 Modeled Contributions at E. 75th St. PM2.5 Monitor

so4 28%

no3 12%

oc 25% ec 4% soil 4% nh4 13% pbw 10% blan 4%

so4

no3

oc

ec
soil

nh4 pbw

blan

2005 Modeled Contributions to Mann Road PM2.5 Monitor

so4 32%

no3 10%

oc 22% ec 4% soil 3% nh4 14% pbw 11% blan 4%

so4

no3

oc

ec
soil

nh4 pbw

blan 2009 Modeled Contributions to Mann Road PM2.5 Monitor

so4 28%

no3 12%

oc 25% ec 4% soil 4%

nh4 13% pbw 10% blan 4%

so4

no3

oc

ec
soil

nh4 pbw

blan

2005 Modeled Contributions at E. Michigan St. PM2.5 Monitor

so4 32%

no3 11%

oc 23% ec 4% soil 3%

nh4 14% pbw 10% blan 3%

so4

no3

oc

ec
soil

nh4 pbw

blan 2009 Modeled Contributions at E. Michigan St. PM2.5 Monitor

so4 27%

no3 12%

oc 26% ec 4% soil 4%

nh4 13% pbw 10% blan 4%

so4

no3

oc

ec
soil

nh4 pbw

blan41 Results of the Round 5 PSAT modeling for Central Indiana fine particle monitors show the highest pollutant contributors to base-case and future year fine particle concentrations are sulfate, organic carbon, ammonium, and nitrat e. Future year modeling show s decreases in sulfates (due to the emission reductions from CAIR) and amm onium. The future year modeling did show slight increases in organic carbon and nitrates from the base-case modeled concentrations.

7.4 Summary of Existing Modeling Results

U.S. EPA and LADCO modeling for future year design values ha ve consistently shown that existing national emission control measures will br ing the Central Indiana Area into attainment of the annual NAAQS for fine particles. Emissi on control measures to be implemented in the next several years will provide even greater assu rance that air quality w ill continue to meet the standard into the future. Modeling support for CA IR has shown that future year design values for the Central Indiana Area will continue to atta in the annual standard for fine particles with modeled future year design values below 15 μg/m 3 . U.S. EPA future year modeling of national emission control strategies will ensure that the Central Indiana Area will maintain lower fine particle concentrations with an increasing margin of safety.

7.5 Meteorological Analysis for Central Indiana

Meteorological conditions are one of the most important factors that influence development and transport of fine particles. Stagnant surface conditions during any time of the year and upper air ridging provides conducive conditions for develo pment and transport of fine particles. Ultimately, passage of surface cold fronts with a clean air mass ch ange will lower fine particle readings in the Central Indiana Area.

7.6 Surface Air Conditions Present During High Fine Particle Concentration Days

Higher annual concentrations of fine particles tend to correlate with warmer temperatures and lighter wind speeds, although high fine particle ep isodes can occur in the summer or winter. It should be noted that higher annual fine particle co ncentrations are driven by individual days with higher fine particle concentrations throughout the monitored y ear. Therefore, it is difficult to attribute higher fine particle concentrations to annualized mete orological rankings. Review of several of the higher fine partic le concentration episodes over th e past few years reveal that conditions were hot in the summer with temperatures in the middle 80 o s Fahrenheit or higher and average wind speeds were fairly light. Fall and winter days with higher fine particle concentrations had near normal temperatures, bu t wind speeds were very light and humidity was higher.

7.7 Upper Air Conditions Present During Hi gh Fine Particle Concentrations Days

Upper air ridges and more stagnant surface wind conditions predominately affect development and build up of fine particles. Slow movi ng upper air ridges can effectively suppress mixing within the many levels of the atmosphere and caus e pollutants to build up over time. Inversions or increases in temperature with a rise in al titude will prevent mixing with air from the upper atmosphere. These conditions can occur at any time of the year and are evident in elevated fine42 particle episodes in spring, summer, fall, and wi nter months. Review of surface and upper air features of higher fine particle concentration days showed sta gnant surface conditions and upper air ridges existed on those days and helped in the buildup of fine particle concentrations.

7.8 Analyses of Atmospheric Conditions Du ring High Fine Particle Concentration Days

Analyses have been conducted to determine the atmospheric conditions that are most prevalent during higher fine particle con centration days in Indiana. L ADCO applied a Classification and Regression Tree (CART) analysis to data from Indiana that correla ted different le vels of fine particle concentrations to meteorological conditi ons from 1999 to 2004 (Donna Kenski, 2005). This type of analysis evaluates meteorological conditions, such as temperature, pressure, wind speed, wind direction, relative humidity, and dew poi nt temperatures at the surface, as well as morning and evening mixing heights in the upper atmosphere which were present when higher concentrations of fine particles were monitored. Results of this CART analysis indicated factors that played a larger role in higher fine partic le concentrations in Indiana were warm-weather conditions with high dew points, southwest winds, and high eveni ng mixing heights. Previous day’s concentrations of fine particles play a key role in higher impacts as well.

Fine particles are made up of severa l constituents, including direct PM 2.5 , sulfates, nitrates, ammonium, organic carbon, and elemental car bon. Depending on the time of the year, concentrations of fine particle constituents vary, with nitrates being more prevalent in the winter and sulfates more prevalent in the summer. Sulfate and nitrate emission reductions have the biggest impact on lower future year fine particle concentrations.

7.9 Summary of Air Quality I ndex Days in Central Indiana

An analysis was conducted to review the daily fine particle concentrations over a year to determine the Air Quality Index (AQI) trends. Chart 7.8 shows by year (2001 through 2010), the percentage number of days during the calendar y ear which fine particle concentrations reached the AQI ranges for “Good” (0 to 15.3 μg/m 3 ), “Moderate” (15.4 μg/m 3 to 40.4 μg/m 3 ), and “Unhealthy for Sensitive Groups (USG)” (40.5 μg/m 3 to 65.4 μg/m 3 ). There were no days during which fine particle levels re ached the “Unhealthy” level of 65.5 μg/m 3 to 150.4 μg/m 3

.43 Chart 7.8 Distribution of PM 2.5 Concentration Days in Central Indi ana on the AQI Levels of Health

Table 7.5 shows how the years ranked for the th ree AQI ranges. The year 2009 had the most “Good” concentration days during the 10-year period analyzed (2001 through 2010). The year 2007 had the most “Moderate” concentration da ys and the year 2005 had the most “USG” concentration days with no days recorded in 2003, 2004, 2006, 2008, and 2009. As can be seen, weather plays a large role in fine particle concentration de velopment and transport as 2001, 2002, 2005, and 2007 were warmer than normal summ ers which translated to moderate and unhealthy for sensitive group levels of air quality.

Table 7.5 Ranking and Percentage of Highest Number of Days at AQI Levels of Health Concern

Ranking Good Moderate Unhealthy for Sensitive Group 1 st 2009 – 72% 2007 – 51% 2005 – 2% 2 nd 2006 – 69% 2001 – 50% 2001 – 2% 3 rd 2004 – 67% 2002 – 47% 2002 – 1% 4 th 2008 – 64% 2005 – 45% 2010 – 1% 5 th 2003 – 60% 2003 – 40% 2007 – 1% 6 th 2010 – 59% 2010 – 40% 7 th 2005 – 53% 2008 – 36% 8 th 2002 – 52% 2004 – 33% 9 th 2001 – 48% 2006 – 31% 10 th 2007 – 48% 2009 – 28% 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010

Good Moderate USGPercentageofYear

Year44 7.10 Summary of Meteorological Analysis for Central Indiana

Annual fine particle concentrations in the Centra l Indiana Area are driven by higher fine particle concentration days that can occur during any ti me of the year. Conditions that are most prevalent during higher fine pa rticle concentration days are lighter winds, higher relative humidity, and above average temperatures in th e summer, and near normal temperatures in the fall, winter, or spring. Approxima tely 70% of the days when PM 2.5 concentrations were in the USG range occurred in the summer months with maximum high temperatures of 80oF or above. Weather plays a large role in fine particle concentration de velopment and transport as 2001, 2002, 2005, and 2006 were warmer than normal summer s which translated to more days of moderate and unhealthy for sensitive group levels of air quality. Uppe r air weather patterns generally include ridging over the area with stag nant conditions at the surface caused by lower mixing heights and stable conditi ons for summer episodes and ri dging or troughs over the area in the fall, winter, or spring episodes. Surface wind s from any direction can transport pollutants from surrounding areas into the Central Indiana Ar ea. Nitrates are bigger contributors to fine particle concentrations in the winter and sulfat es are bigger contributo rs to fine particle concentrations in the summer.

8.0 CORRECTIVE ACTIONS

8.1 Commitment to Revise Plan

As noted in Section 4.6, IDEM commits to review and revise, as appropriate, its Maintenance Plan eight years after re designation, as required by S ection 175A of the CAA.

8.2 Commitment for Contingency Measures

IDEM will monitor fine particle concentrations to determine whether trends indicate higher values or whether emissions appear to be increasing. If it is determ ined that fine particle levels and emissions are increasing and action is necessary to reverse that trend, IDEM will take action to reverse the noted trend, prior to a violation of th e standard occurring.

IDEM commits to adopt and expeditiously impl ement necessary corrective action in accordance with an Action Level Response described below.

Action Level Response

An Action Level Response shall be prompted when ever a violation of th e standard (three-year average annual arithmetic mean value of 15.1 μg/m 3 or greater) occurs. In the event that the Action Level is triggered and is not found to be due to an atypical unfavorable meteorological condition, exceptional event, malfunction or noncompliance with a permit condition or rule requirement, IDEM will determine additional co ntrol measures needed to assure future attainment of the annual NAAQS for fine partic les. In this case, measures that can be implemented in a short time will be selected in order to be in place within eighteen months from the end of the year that prom pted the Action Level Response.45 Control Measure Select ion and Implementation

Adoption of any additional control measures is subject to the necessary administrative and legal processes. This process will include publication of notices, an opportunity for public hearing, and other measures required by Indiana law fo r rulemaking by state environmental boards.

If a new measure or control is already promulgated and schedul ed to be implemented at the federal or state level, and that measure or contro l is determined to be sufficient to address the upward trend in air quality, additi onal local measures may be unn ecessary. Furthermore, IDEM will submit to U.S. EPA an analysis to demonstrate the proposed measures are adequate to return the area to attainment.

8.3 Contingency Measures

Contingency measures to be considered will be se lected from a comprehensive list of measures deemed appropriate and effective at the time the selection is made. Listed below are example measures that may be considered. The se lection of measures will be based upon costeffectiveness, emission reduction po tential, economic and social c onsiderations, or other factors that IDEM deems appropriate. ID EM will solicit input from intere sted and affected persons in the maintenance area prior to selecting appropria te contingency measures. All of the listed contingency measures are potentially effectiv e or proven methods of obtaining significant reductions of fine particle precursor emissions. Because it is not possible at this time to determine what control measure will be appropriate at an unspecified time in the future, the list of contingency measures outlined below is not comprehensive. IDEM anticipates that if contingency measures should ever be necessary, it is unlikely th at a significant number (i.e., all those listed below) will be required.

1) Alternative fuel and diesel retrofit programs for fleet vehicle operations. 2) Require NO x or SO 2 controls on new minor sources (less than 100 tons). 3) Wood stove change out program. 4) Idle restrictions. 5) Broader geographic applicabil ity of existing measures. 6) One or more transportation control measur es sufficient to achie ve at least a 0.5% reduction in actual area wide precursor emissions. Transportation measures will be selected from the following, based upon the factors listed above , after consultation with affected local governments: a) Trip reduction programs, including, but not limited to, employer-based transportation management plans, ar ea-wide rideshare programs, work schedule changes, and telecommuting. b) Transit improvements. c) Traffic flow improvements. d) Other new or innovative transportation m easures not yet in widespread use that affected state and local governments deem appropriate.46 No contingency measure shall be implemented w ithout providing the opportunity for full public participation during which the relative costs and be nefits of individual meas ures, at the time they are under consideration, can be fully evaluated.

9.0 PUBLIC PARTICIPATION

Indiana published notification for a public hearing and soli citation for public comment concerning the draft Redesignation Petition and Ma intenance Plan in the Indianapolis Star, Indianapolis, Indian a on April 15, 2011.

A public hearing to receive comments concerni ng the redesignation re quest was conducted on May 17, 2011 at the Indianapolis-M arion County Library-West Indi anapolis Branch, located at 1216 S. Kappes Street, Indianapolis, Indiana. The public comment period closed on May 19, 2011; no comments were received by the agen cy concerning this submission. Appendix K documents the public hearing process and includes a copy of the public notic e, certifications of publication, and transcript from the public hearing.

10.0 CONCLUSIONS

The Central Indiana Area has attained the annua l NAAQS for fine particles. This petition demonstrates that the Central Indiana Area has co mplied with the applicable provisions of the CAA regarding redesignation of non attainment areas for fine part icles. IDEM has prepared a State Implementation and Maintenance Plan that meets the requirement of Section 110(a)(1) of the CAA.

Indiana has performed an analysis that shows the air quality imp rovements are due to permanent and enforceable measures and that additional significant regional NO x and SO 2 reductions following implementation of the Phase II NO x SIP Call rule, and CAIR or its replacement rule will ensure continued compliance (maintenance) with the standard. Furthermore, emission projections indicate that NO x and SO 2 emissions will continue to decline, ensuring that the area continues to maintain compliance with the sta ndard and provide for an increased margin of safety. Based on this presenta tion, the Central Indian a nonattainment area for fine particles meets the requirements for redesignation unde r the CAA (Section 107(d)(3)) and U.S. EPA guidance for fine particles.

Consistent with the authority granted to U.S. EP A, the State of Indiana requests that the Central Indiana nonattainment area for fine particles be redesi gnated to attainment for the annual fine particles standard simultaneously with U.S. EP A approval of this Indiana State Implementation and Maintenance Plan.